Here is the translation of the court decision analysis:
1. Subject of Dispute: Challenging tax notifications-decisions of PJSC “ATASS-Boryspil” regarding the accrual of penalties and additional tax liabilities based on the results of a documentary audit.
2. Main Arguments of the Court:
– Regarding fuel purchase: the court considers that to confirm transactions, not only fiscal receipts are required, but also other primary documents.
– Regarding amortization of the recreation base: the court pointed out the need for a more detailed examination of documents confirming the use of the object in economic activity.
– Regarding cash operations: the court essentially deviated from the previous position of the Supreme Court regarding the application of Decree No. 436/95 on penalty sanctions.
3. Court Decision: Partially canceled previous court decisions and referred the case for a new review to further investigate the circumstances of fuel purchase and depreciation accrual.
